Part 108 is not a drone rule. It is an airline rule. Here is what that means for your operation.

Most commercial drone operators are watching Part 108 the way you watch a storm on radar. It is coming, it is probably significant, and you will deal with it when it gets here.

That framing is going to hurt you.

Part 108 is the FAA's proposed framework to make routine BVLOS flight legal without a case-by-case waiver. Today, commercial operators fly under Part 107, which caps drones at 55 pounds and requires the pilot to keep the aircraft in sight. Anything past that needs a waiver the FAA grants one mission at a time. Part 108 ends that model. What replaces it is not simpler. It is more demanding, more structured, and built on assumptions your operation almost certainly does not meet yet.

Part 108 doesn't replace Part 107. If you have no interest in flying beyond visual line of sight, you can stay exactly where you are. This applies to operators who want or need BVLOS, not to every commercial drone operation.

Here is what those assumptions look like in plain language.

Part 108 is built on airline logic, not drone logic

Part 108 is written as performance-based regulation, not a simple checklist rule. The FAA's own framing is that it's meant to create a predictable, safe, and scalable pathway for BVLOS operations, not just a formality you file paperwork for. Read that again. Not a certified pilot. Not a waiver. A program, with defined roles and oversight, that has to hold up under FAA review before you fly.

That is how Part 121 airlines operate. That is not how the commercial drone industry currently operates, with a few exceptions.

Part 108 requires coordinated teams, not solo experts, regardless of which authorization tier you pursue. The rule requires every operator, permitted or certificated, to designate an operations supervisor, who holds strategic operational control over the entire operation, and one or more flight coordinators, who provide tactical, per-aircraft oversight. Neither role requires an FAA-issued airman or remote pilot certificate. What certificated operators additionally take on is a full safety management system, a requirement permit holders don't carry.

If you're planning to move into BVLOS and your current operation is one pilot, one drone, and a Part 107 certificate, you are not looking at an upgrade. You are looking at a rebuild.

Where things actually stand

Following the NPRM and the public comment period that concluded in February 2026, the industry is now awaiting publication of the final rule. The FAA reopened its comment period twice, the second time specifically to take more input on contested right-of-way provisions. By the FAA's own count, more than half of the roughly 3,100 substantive comments addressed the right-of-way question alone. That is not a rule about to ship. That is a rule the agency is still fighting to settle.

The timeline has already slipped. Do not let that create complacency. The structural requirements are not changing: the operational control requirements, the personnel roles, the documentation standards.

Two things you can do now

Neither of these requires writing a policy against a rule that isn't final yet. Both are work you'd want done regardless of what the final text says.

First, standardize your go/no-go: the decision, before anything leaves the ground, that the mission is fit to fly. This is the Planning phase, and it's where operational control actually lives, because the authority to stop the mission sits here and nowhere later. Build it as a single repeatable gate you run the same way every time: crew fitness, airworthiness, weather against your own minimums, airspace and route authorization, and a verified return-to-home altitude set before launch. The consistency matters more than any single line, it's what keeps you from missing something when you're distracted or the situation shifts. The Return to Home Readiness Checklist builds this out as Phase 01 of the full mission, then carries the same discipline through Launch, Enroute, Return, and Post Flight, each phase organized by who holds authority, and written to sit above the regulation rather than just meet it.

Second, start a gap analysis. The NPRM is public now. There's no reason to wait for the final rule to find out where your current Part 107 procedures fall short of what Part 108 will require. Pull your existing policies next to the proposed rule text and mark where they diverge. You're not putting anything into effect. You're finding out how much work is ahead of you before the deadline forces you to find out the hard way.

Reply and tell me if you've started a Part 107 vs Part 108 gap analysis yet.

With more than two decades of experience across airline dispatch, operational control, and safety management systems, Jamie Killoch also holds an FAA Part 107 Remote Pilot Certificate, bridging manned aviation discipline with commercial UAS operations.